Checklist

CSA readiness self-check

One tab per system, thirty-six checks in eight sections — the four CSA steps, the two ways the risk call goes wrong, what an unscripted record has to contain, where vendor evidence stops, and the questions an inspection puts to eQMS validation.

Computer software assurance changes where validation effort goes, not whether the evidence exists. This self-check walks one system — or one module of an eQMS — through the route FDA's guidance describes and asks, row by row, whether the evidence you kept matches the route you claim: an intended use per feature rather than a system description, a risk call with a reason a stranger could follow, scripted tests on the high-process-risk functions and a real record for the unscripted ones, vendor evidence assessed rather than filed, and a record tied to the software version with a signature on it. The last section is the rehearsal: the seven questions an investigator puts to eQMS validation, each of which a well-kept record answers in under a minute. It is the companion to what software assurance means under inspection and the CSV vs CSA decision tree.

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CSV vs CSA decision tree
CSA readiness self-check — the Excel workbook you download, showing its section, check, evidence and status columns

What the self-check covers

The workbook has two tabs. An Instructions tab explains how to run the list, what each column means, and the four texts the rows rest on. The Self-check tab is one copy per system: thirty-six checks in eight sections, each stating what the validation record must show for the check to pass, with a Pass / Gap / N-A dropdown, a column for the evidence reference, and a notes column for what is missing and who owns closing it.

The sections follow the route itself. Section 1 asks whether intended uses are written per feature, in the site's words. Section 2 is the risk call — one per intended use, answering the CSA question rather than a general risk score, and rated neither all-high (the old scripted pack relabelled) nor all-not-high (a two-line note where the release decision needed a scripted test). Section 3 covers the assurance activities: scripted tests with expected results on the high-process-risk functions, and for the rest an unscripted pass whose record says who tested, when, on which version, what they tried, what they saw, and who signed. Section 4 is vendor evidence — assessed once, leveraged where intended uses overlap, never a substitute for the site's own call. Section 5 is the record; section 6 is what happens at each release; section 7 is the inspection rehearsal.

  • Intended use per feature — capture, routing, investigation, CAPA linkage, approval to close, the audit trail, the dashboard — each on its own line
  • A process-risk call per intended use with a reason, and both failure modes checked: everything rated high, everything rated not-high
  • Scripted evidence for the high-risk functions; a five-part record for every unscripted pass
  • Vendor evidence assessed, leveraged where the intended use overlaps, and never the only line on the record
  • A record tied to the software version, reviewed and approved — and the seven questions an investigator asks, each answerable in under a minute

How to use it

Copy the Self-check tab once per system, or once per module of an eQMS, and fill the four record-header rows first — the system, the software version, who assessed and who approves. Then work the sections in order with the validation record open beside you. Each check says what the record must show: mark Pass only when you can point at it, and put the pointer — document and section, record ID, system location — in the evidence-reference column. Gap means the record does not show it. N-A needs a reason in the notes.

Section 7 is where the sheet earns its keep. Take each of the seven questions — show me the intended use for this module; how did you decide how much to test it; show me the evidence for the approval workflow; what did you do for the reporting screens; what changed in the last release and what did you re-check; who reviewed and approved this record; where is the vendor's evidence and what did you do with it — and answer it from the record with a stopwatch running. Any Gap in sections 2, 3 or 5 is a finding to close before the next release, not a note for the next periodic review. The CSV vs CSA decision tree is the one-page version of the risk call; the validation master plan template is where the approach is declared before any of this is executed.

How an inspector reads this

Investigators do not audit a methodology. They pick a function — usually the approval workflow — and pull the thread: intended use, how much testing was decided and why, the evidence on this version, what was re-checked at the last release, who approved the record. FDA's guidance Computer Software Assurance for Production and Quality Management System Software (issued 3 February 2026, superseding the September 2025 issue) defines a high process risk as a failure that may result in a quality problem that foreseeably compromises safety, accepts unscripted testing as an assurance activity, lets validation work already performed by developers and suppliers be the starting point, and lists what the record should contain — the intended use, the result of the risk-based analysis, a description of the testing, the issues found, a conclusion on acceptability, who did it and when, and review and approval. The rows in this workbook are that list, turned into questions.

What produces observations is not the absence of a script. It is a record that cannot show why light testing was reasonable for a function that decides whether product ships, or a record that says "vendor tested it" and nothing more — which reads as no assessment at all. The self-check is built to find both before an investigator does.

Frequently asked questions

What is the difference between CSV and CSA?

Same objective, different route. Computer system validation as most sites practised it scripted everything to the same depth. Computer software assurance starts from the intended use of each feature, asks whether its failure could foreseeably lead to a quality problem that compromises safety, and puts scripted testing on the functions where the answer is yes — with documented unscripted testing, and vendor evidence assessed and leveraged, for the rest. The evidence still exists; the effort visibly follows the risk.

Is unscripted testing acceptable evidence?

Yes, when the record shows the method was chosen deliberately and was actually performed: the feature and its intended use and risk call, who tested and when and on which version, what was tried in a few lines, what was observed, and a conclusion with a signature. "Exploratory testing performed, no issues" with nothing behind it is the version that produces observations. Section 3 of the self-check checks for the five parts.

Can I rely on the vendor's testing?

As input, not as a substitute. A supplier's evidence covers the supplier's intended use and configuration; where yours overlaps it reduces how much you re-test, and a supplier assessment on file is what makes leveraging defensible. It does not replace your intended-use assessment, your risk rationale or your record — a line that says only "vendor tested it" reads as no assessment. Section 4 checks each of those.

Bring one Gap row to a validation walkthrough

Book a demo and put the row your record could not answer to the validation pack — the intended-use list, the risk rationale, the scripted evidence for the approval workflow — so what you see is the record, not a slide about it.